The categories of personal information we collect depend on how you interact with us, our Services and the requirements of applicable law. We collect information that you provide to us, information we obtain automatically when you use our Services, and information from other sources, such as third-party services and organizations, as described below (collectively, “Personal Data”). 

1. 1. Personal Data you provide

You provide your personal data when creating an account to use the Service in our application. We may collect the following personal information that you provide to us.

(a) Account сreation. We may collect information when you create an account, including your name, profile name, phone number, email address, and Google or Apple profile details.

(b) Your content. We may collect videos that you upload from your device while using our application. Please note, you won’t be able to upload content from your camera roll unless we can access your device’s camera.

(с)Generated content. We may also collect and store the content you generate within our application, including your edited videos. 

(d) Usage data. When you use our Services, we may collect information about your activity within our Services, for example, which pages you have viewed and for how long. We may also collect IP addresses, the source of the traffic, information regarding the device and operating system, details about your wireless and mobile network connections, unique device identifiers, browser type, language, battery level, and time zone. We collect such data as IP address, your device model, screen resolution, and operation system, session durations, and your location. This data helps us to analyze your needs and interests, evaluate the effectiveness of our campaigns, and improve our application.

(e) Purchases. We may provide paid features to our users. To allow such paid features, we may collect personal information and details associated with your purchases, including payment information. In some cases, you may need to provide us with additional information to verify your identity before completing a transaction. Any payments made via our Services are processed by third-party payment processors. We do not directly collect or store any payment card information entered through our Services, but we may receive information associated with your payment card information (e.g., your billing details).

(f) Your Communications with us. We may collect personal information, such as email address and phone number, when you request information about our Services, request customer or technical support, or otherwise communicate with us.

1. 2. Data collected automatically

When you visit a website and/or application, you disclose certain information, such as your IP address and the time of your visit. This site, like many others, records basic information about visits to our site. In particular, we collect the following data:

(a) data about how you found us. We collect data about your referring app or URL (the app or place on the Web where you were when you tapped on our ad). 

(b) device and location data. We collect data from your device. Examples of such data include language settings, IP address, time zone, type and model of a device, device settings, operating system, Internet service provider, mobile carrier, hardware ID, and Facebook ID. 

(с) usage data. We record how you interact with the Service. For example, we log your taps on certain areas of the interface, the features, and the content you interact with. We also record the ads on our website with which you interact (and the Internet links to which those ads lead).

(d) advertising IDs. We collect your Apple Identifier for Advertising (“IDFA”) or Google Advertising ID (“AAID”) (depending on the operating system of your device). You can typically reset these numbers through the settings of your device’s operating system (but we do not control this).

1. 3. Information collected from other sources 

We may obtain information about you from other sources, including through third-party services and organizations. For example, if you access our Services through a third-party application, such as an app store, a third-party login service, or a social networking site, we may collect information about you from that third-party or third-party application that you have made available via your privacy settings.

1. 4. Cookies and similar tracking technologies 

Our products employ technologies (cookies, SDKs, etc.) to process your data to enhance your user experience, optimize ads, and analyze traffic. These technologies are activated when you interact with our Services, visit our website, or use our application. Disabling these technologies may affect the functionality of certain features, although our products will remain usable.

Furthermore, our partners and we utilize targeting technologies to tailor ads, potentially displaying them to you at relevant moments. When enabled, your interactions with our website or application may result in seeing our ads on social media platforms, helping us measure the effectiveness of our ad campaigns. We use, in particular, the following categories of tracking technologies:

Strictly necessary

Our products and their features require certain technologies to function properly. These technologies are typically activated when you request our Service, for example, when you visit our website or open the application. By utilizing them, we can (i) remember your preferences as you navigate our products, (ii) ensure swift loading of the content you request, (iii) enhance the security of our products, and (iv) enable other functionalities of our products.

Functional

We use functional technologies to personalize and enhance your experience. By utilizing them, we can remember your choices (for example, custom design settings or storing your language preference for an extended period). Additionally, they provide you with a more consistent user experience by remembering your settings, keeping you logged in for extended periods, or saving your shopping cart selections.

If you disable these technologies, some features may not function properly, although you will still be able to use our products.

Performance

We use performance technologies to process information about how you and others interact with our products. This helps us understand user engagement with our products and features, and identify preferences or dislikes. Some examples include:

- Counting visits and identifying traffic sources.

- Understanding which sections or features are most favored.

- Analyzing user preferences to help us decide what new features to build.

When you disable performance technologies, we will not receive certain information that we process for analytical purposes.

Targeting

We, and our partners, use targeting technologies to tailor ads and possibly even display them to you at relevant times. For instance, if these technologies are enabled and you interact with our website or application, you might see ads for our products in your social media feeds. Additionally, they help us measure the effectiveness of advertising campaigns and make advertising more relevant to you.

We do not collect any special categories of personal data as defined by Article 9 of the GDPR or other sensitive personal data (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership).

We ask that you not send us, nor disclose, any sensitive personal data through the Service or otherwise to us.

If you send or disclose sensitive personal data to us when you use the Service, you must consent to our processing and use of such sensitive personal data under this Privacy Policy. If you do not consent to our processing and use of such sensitive personal data, you must not submit such sensitive personal data through the Service.

Access to your Personal Data may be provided to third parties who provide technical support for the operation of our website and application. We also share information with third parties that help us operate, provide, improve, and customize our Service. 

4. 1. service providers

We share personal data with service providers that support our Service and business operations, acting on our instructions or, in some cases, as independent controllers.

(a) Data analytics and performance measurement providers

We utilize analytics tools to understand how users interact with our Service, measure performance, identify issues, and enhance functionality.

These providers may process technical and usage data such as device identifiers, approximate location, IP address, timestamps, interaction events, and diagnostic information.

Our analytics providers include, in particular:

• Firebase Analytics: to analyze user interactions within our apps and measure engagement and retention.
• Google BigQuery: to store, aggregate, and analyze analytics and operational data in a scalable cloud-based environment.
• Amplitude: to understand how users interact with specific features of the Service and to analyze behavioral patterns.
• RevenueCat: to analyze subscription performance, in-app purchases, and revenue-related metrics.
• Paddle: to analyze subscription performance, in-app purchases, and revenue-related metrics.

These tools help us understand usage trends, improve user experience, and make informed product and business decisions.

(b) Advertising, attribution, and marketing measurement partners

We work with advertising platforms and attribution providers to promote our Service, measure advertising effectiveness, prevent fraud, and optimize marketing campaigns. These partners may process identifiers such as device IDs, advertising IDs, cookies, IP addresses, and event data (e.g., app installs or purchases).

Our advertising and marketing partners include, in particular:

• Meta Platforms, Inc. (Facebook, Instagram): for ad delivery, conversion tracking, and audience measurement.
• Google LLC (Google Ads, YouTube): for ad delivery, remarketing, and campaign performance measurement.
• Snap Inc. (Snapchat): for advertising, conversion tracking, and attribution.
• TikTok Inc.: for advertising and campaign performance measurement.
• AppLovin Corporation: as an advertising and monetization platform.
• Pinterest, Inc.: for advertising, conversion tracking, and audience measurement.
• X Corp. (formerly Twitter): for advertising and conversion tracking.
• Adjust GmbH: for mobile attribution and advertising performance analytics.

These partners may act as independent controllers for their own advertising and measurement purposes, in accordance with their respective privacy policies.

4. 2. law enforcement agencies and other public authorities

We may use and disclose personal data to enforce our Terms of Use, to protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or others, and to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, or in other cases provided for by law.

4. 3. third parties as part of a merger or acquisition

We may buy or sell assets or business offerings as we develop our business. Customers’ information is generally one of the transferred business assets in these transactions. We may also share such information with any affiliated entity (e.g., parent company or subsidiary) and may transfer such information in the course of a corporate transaction, such as the sale of our business, a divestiture, merger, consolidation, or asset sale, or the unlikely event of bankruptcy.

4. 4. professional advisors

We may disclose your personal information to professional advisors and our contractors, such as lawyers, bankers, auditors, and insurers, where necessary in the course of the professional services that they render to us.

4. 5. affiliates 

We may disclose Personal Information to our affiliates, meaning an entity that controls, is controlled by, or is under common control with Elvalabs LTD. Our affiliates may use the Personal Information we share in a manner consistent with this Privacy Policy.

You have the following rights regarding your Personal Data:

5. 1. Accessing / reviewing / updating / correcting your personal data. You have the right to review, edit, or change the personal data that you had previously provided to us in your account. Please send us a data access request if you would like to receive a copy of the data we process. Such requests can be sent to [email].

5. 2. Delete. You may also ask us to delete your Personal Data, and we will honor your request to the extent possible. In some instances, we may be legally required to keep your Personal Data. in such event, we will fulfill your request in relation to portion of the data within the timeframes required for exercising data deletion requests and to another portion of the data after we have complied with our retention obligations (for example, after the end of data retention period obligation for payment data).

5. 3. Getting to know the details of the processing. You have the right to be informed about the collection and use of your personal data. This means that you have the right to understand what personal data is being processed, why it's

being processed, who it's being shared with, how long it's being stored. 

5. 4. Restrict. You may ask to stop or limit the processing of all or part of your Personal Data. 

Additional information for EEA-based users. If you are based in the EEA, you have the following rights in addition to the above:

(I) The right to submit a complaint to the supervisory authority. We encourage you to contact us directly so that we can address all your concerns. Nevertheless, you have the right to submit a complaint to a competent data protection supervisory authority, in particular in the EU Member State where you reside, work, or where the alleged infringement has occurred.

(II) The right to data portability. If you wish to receive your personal data in a machine-readable format, you can request a copy of your personal data as described above. 

5. 5. Opt-out. You may ask us to stop sending you direct marketing communications. We may continue to send emails that relate to the Service provision and are not marketing-related. 

5. 6. Object. Object to our reliance on our legitimate interests as the basis of processing your Personal Data.

5. 7. The right to lodge a complaint with supervisory authority. We would love you to contact us directly, so we could address your concerns as customer satisfaction is our top priority, thus we strive to appoint sufficient resources and efforts to provide you with top of the market customer support and most likely will be able to satisfy your request directly. Nevertheless, you have the right to lodge a complaint with a competent data protection supervisory authority.

You can exercise the above-mentioned right and submit your requests by emailing us at the address indicated in section 12. We may request specific information to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why subject to legal restrictions.

This section applies only to residents of the specific states in the US.

If you are a resident of the US state where the specific state privacy law was enacted (in particular, California, Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, Virginia), you may have specific rights in addition to the general privacy rights provided above. 

These rights include: (i) to opt out of the processing of the personal data for purposes of the sale of personal data; (ii) to opt out of the processing of the personal data for purposes of targeted advertising/cross-contextual behavioral advertising. 

We may share certain information about you with our partners for purposes of targeted advertising or data analytics, which could, in certain circumstances, be characterized as “selling,” “sharing,” or “targeted advertising” under US state laws. You have the right to opt-out of such sale/sharing of your personal information.

6. 1. California privacy rights

California residents have the following rights under the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA):

(a) Right to know what personal information is sold or shared and to whom. Under that title, you have the right to request that we disclose to you:

(I) The categories of personal information that we collected about you.

(II) The categories of personal information that we sold or shared about you and the categories of third parties to whom the personal information was sold or shared, by category or categories of personal information for each category of third parties to whom the personal information was sold or shared.

(III) The categories of personal information that we disclosed about you for a business purpose and the categories of persons to whom it was disclosed for a business purpose.

(b) Right to limit the use of sensitive data. Under this title, you have the right to direct us to limit our use of your sensitive personal information to that use which is necessary to perform the services or provide the goods reasonably expected by an average consumer who requests those goods or services.

(с) Right of no retaliation following opt out or exercise of other rights. Under this title, you have a right not to be discriminated against for exercising any of your rights under the CPRA. 

To exercise your privacy rights, please send a request to support@elva-labs.com or use the privacy features available in our products.

California also provides its residents with additional access rights. Under the California Civil Code Section 1798.83, also known as California's “Shine the Light” law, the residents may ask companies once a year what personal information they share with third parties for those third parties’ direct marketing purposes. 

To obtain this information from us, please send an email message to support@elva-labs.com, which includes “Request for California Shine the Light Privacy Information” on the subject line and your state of residence and email address in the body of your message. Please be aware that not all information sharing is covered by the “Shine the Light” requirements,х and only information on covered sharing will be included in our response.

6. 2. Appeal

Under the US state privacy laws, if your privacy request is denied, you have the right to appeal that decision within a reasonable timeframe. 

To appeal our decision regarding your request, you can contact us, clearly indicating 'USA PRIVACY APPEAL REQUEST' in your message.

While submitting your appeal, please include a copy of or otherwise specifically reference our decision on your privacy request, so we can adequately review and address it.

We may transfer Personal Data to countries other than the country where the data was originally collected to provide the Service provided for in the Terms of Service and for purposes indicated in this Privacy Policy. We deploy special safeguards if these countries do not have the same data protection laws as the country where you initially provided the information.

As we operate in countries worldwide (including in the US) and use technical infrastructure in the US to deliver the Website and application to you, we need to transfer your personal information to the US and to other jurisdictions as necessary to provide the Services. Simply put, we cannot provide you with the Services and perform our contract with you without moving your personal information around the world.